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Compliance walkthrough

How to comply with Saudi Arabia's PDPL: video walkthrough

A walkthrough of building a compliance programme for Saudi Arabia's Personal Data Protection Law, from scoping to records the regulator can inspect.

  • Compliance walkthrough
  • 3 min 15 s

Key takeaways

  • The PDPL applies in Saudi Arabia and to processing abroad about its residents.
  • Consent is the starting point, with defined exceptions.
  • Controllers publish a privacy policy and keep a record of processing activities.
  • Breaches are notified through SDAIA's National Data Governance Platform.
  • Registration certificates record registration, not compliance.

Saudi Arabia's general personal data law

The Personal Data Protection Law is Saudi Arabia's general law on personal data. It governs processing of personal data in the Kingdom by any means, and reaches organisations abroad that process personal data relating to its residents. It gives individuals rights over their data, makes consent the starting point, and requires controllers to publish a privacy policy, secure data, report breaches, assess the impact of processing, keep a record of processing activities and send data abroad only on defined terms.

The Saudi Data and Artificial Intelligence Authority, SDAIA, supervises and enforces the Law and runs the National Data Governance Platform, where controllers register and notify breaches. Registration produces a registration certificate, which records registration, not compliance; no certificate of compliance is issued under the Law. This short film walks through how a programme is built.

Build it, run it, then demonstrate it

Settle what the programme has to cover: the entities in and outside the Kingdom, the organisation's role as controller or processor for each activity, any sector regulators, whether registration and a data protection officer are required, and who will judge the result. A gap analysis then compares current practice with the Law and SDAIA's Implementing Regulation and Transfer Regulation.

Implementation records each processing activity with its purpose and legal basis, obtains consent where the Law requires it and documents the cases where another basis applies, publishes the privacy policy, and sets up a request procedure with identity checks and a log that keeps deadlines visible, so individuals can be informed, access their data, obtain it in a readable form, have it corrected and have it destroyed once it is no longer needed. Security controls, breach notification through the platform, impact assessments, processor contracts and safeguards for transfers outside the Kingdom complete the programme. The record of processing activities is kept ready for inspection. SDAIA and clients' auditors judge whether the programme is enough.

Sterling's expert and experienced consultants design and implement the programme with your team under Sterling OS™. The Law has been in force since 14 September 2023, and its one-year adjustment period ended on 14 September 2024; legal interpretation stays with your legal advisers.

PDPL (Saudi Arabia) at a glance

Purpose
Personal data protection in Saudi Arabia: lawful, transparent and secure processing, rights people can exercise, and records the regulator can inspect
Relevant to
Any organisation processing personal data in the Kingdom, and organisations outside it that process personal data relating to its residents; purely personal or family use is excluded
Edition
Personal Data Protection Law, Royal Decree M/19 of 16 September 2021, amended by Royal Decree M/148 of 27 March 2023; in force since 14 September 2023, and the one-year adjustment period ended on 14 September 2024
Certification
No certificate of compliance is issued under the Law itself. SDAIA supervises and enforces; registering on its National Data Governance Platform produces a registration certificate, which records registration, not compliance
Sterling's role
Programme design and consulting with your team, Effivity, training, internal audit and readiness for SDAIA or client review, then Sustain™
Cost and timing
Total investment for a Saudi PDPL compliance programme depends on the current maturity of your processes, the scope, locations and number of employees. The process typically takes 3 to 8 months

PDPL (Saudi Arabia): the complete guide →

PDPL (Saudi Arabia): questions people ask

Is there a Saudi PDPL certification?

No certificate of compliance is issued under the Law itself. SDAIA supervises and enforces it; registering on its National Data Governance Platform produces a registration certificate, which shows that you registered, not that you comply. ISO/IEC 27701 certification from an accredited body is a separate, voluntary credential that does not replace the Law's obligations. If anyone offers a "PDPL certificate", ask who issues it and under which SDAIA rule, and check that rule on SDAIA's platform.

Does the PDPL apply to organisations outside Saudi Arabia?

Yes, where they process personal data relating to residents of the Kingdom: Article 2 covers such processing by any party abroad, and SDAIA's platform has a registration route for entities outside the Kingdom. A regional head office, an offshore service centre or an online shop with Saudi customers should map what it processes about residents and where the data goes.

When did the PDPL take effect, and is there still a grace period?

The Law came into force on 14 September 2023. Controllers had one year to adjust, and that period ended on 14 September 2024, so the Law applies in full and SDAIA enforces it. If your programme is not yet built, start where exposure is highest: legal bases, breach handling, transfers and the record of processing.

Do we have to register with SDAIA?

SDAIA's rules for the National Register of Controllers set who must register on the National Data Governance Platform, and in practice they reach most controllers. A private company registers through an authorised representative, delegated through business.sa, and the process includes the check on whether a data protection officer is mandatory.

Do we need a data protection officer?

Article 30 of the Law leaves this to the Implementing Regulation, whose Article 32 requires an appointment in three cases: public entities providing services that involve large-scale processing of personal data, controllers whose core activities require regular and continuous monitoring of individuals on a large scale, and controllers whose core activities consist of processing sensitive data. SDAIA publishes rules for the appointment and a tool on its platform to test whether the duty applies. Document the decision either way.

More PDPL (Saudi Arabia) questions and answers →

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